## Facts

- Danuel Dean Quaintance and Mary Helen Quaintance founded the “Church of Cognizance,” which claimed marijuana was a deity and sacrament.
- After Mary Quaintance’s brother, Joseph Butts, was stopped in Missouri and officers found about 338 pounds of marijuana in his pickup, he was arrested.
- The Quaintances sought to raise roughly $100,000 for Butts’s bail and contacted Timothy Kripner about “a job.”
- At their Arizona home, the Quaintances proposed that Kripner pick up marijuana in New Mexico and deliver it to California to generate bail funds.
- Kripner had previously sold the Quaintances marijuana and small amounts of cocaine; he described their dealings as regular purchases consistent with resale activity.
- The night before the planned transport, the Quaintances had Kripner sign a church membership pledge and gave him a certificate designating him an “authorized courier,” without discussing tenets or ensuring he read the pledge.
- Law enforcement intercepted the planned marijuana transaction; the Quaintances and Kripner were arrested and charged with conspiracy and possession with intent to distribute marijuana.
- The Quaintances moved to dismiss the indictment under RFRA, asserting the prosecution substantially burdened their sincere religious exercise.
- After an evidentiary hearing, the district court denied the motion, finding the claimed beliefs were not sincerely held and were used as a pretext for drug trafficking.
- The Quaintances entered conditional guilty pleas preserving the right to appeal the RFRA ruling.

## Issues

1. Whether RFRA barred prosecution because enforcing federal drug laws substantially burdened the defendants’ sincere religious exercise.
2. Whether the district court clearly erred in finding the defendants’ asserted religious beliefs about marijuana were not sincerely held but served as a secular pretext.

## Decision

- The Tenth Circuit affirmed the denial of the RFRA-based motion to dismiss.
- The court held the district court did not clearly err in finding the defendants insincere in their claimed religious beliefs.
- Because sincerity is a threshold requirement under RFRA, the court did not reach substantial burden, compelling interest, or least restrictive means.

## Legal Principles

- RFRA protects against federal actions that substantially burden a sincere religious exercise unless the government satisfies strict scrutiny.
- Courts may assess the sincerity of claimed religious beliefs, while not judging the truth or orthodoxy of the beliefs.
- Sincerity determinations are factual and reviewed on appeal for clear error, with substantial deference to the trial court’s credibility findings.
- When a religious claim is found insincere or used as a sham to mask secular objectives, RFRA provides no defense.

## Conclusion

The court upheld the prosecution because the defendants failed to establish a sincere religious exercise under RFRA, and the district court’s fact-bound finding of insincerity was not clearly erroneous.


United States v. Quaintance, 608 F.3d 717 (10th Cir. 2010)